ML20100G887
| ML20100G887 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 02/20/1996 |
| From: | Storz L Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LR-N96044, NUDOCS 9602260300 | |
| Download: ML20100G887 (9) | |
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e Pubhc Service Doctric and Gas Cwnpany Louis F. Storz Pubhc Service Electric and Gas Company P.O. Box 236. Hancocks Bridge, Rl 08038 601339-5700 i
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LR-N96044 FEB 2 01996 l
United States Nuclear Regulatory Commission Document' Control Desk
. Washington, DC 20555 Cantlemen:
i EXEMPTION REQUEST FROM THE REQUIREMENTS OF 10CFR50 APPENDIX J, SECTION III.D.3.
HOPE CREEK GENERATING STATION
. FACILITY OPERATING LICENSE NPF-57 j
DOCKET NO. 50-354
'Public Service Gas and Electric Co. (PSE&G) requests that the Nuclear Regulatory Commission exempt Hope Creek Generating Station from the requirement of 10CFR50 Appendix J, Section III.D.3, to be able to perform Type C containment leak testing (Local Leak Rate Test) during power operation as well as during each reactor shutdown for refueling.
PSE&G has reviewed the proposed exemption in accordance with the criteria of 10CFR50.12 and believes the proposed change is acceptable.
1 PSE&G is referencing a similar exemption request and the subsequent granted exemption transmittal dated August 31,1995, from the Houston Lighting and Power Company for its South Texas Project Electric Generating Station.
Sincerely,
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JWK/tcp Attachments:
1.
Description of Proposed Changes 2.
Impact on Technical Specifications i
3.
Evaluation in Accordance with 10CFR50.12 4.
Reference to Granted Exemption l
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FEB 2 01996 Document Control Desk 2
LR-N96044 C
Mr.
T. T. Martin, Administrator-Region I U.
S.
Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr.
D. Jaffe, Licensing Project Manager-Hope Creek U.
S.
Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr.
R. Summers (X24)
USNRC Senior Resident Inspector Mr.
K.
Tosch, Manager, IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625 95-4933
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9 ATTACHMENT 1 DESCRIPTION OF PROPOSED CHANGES
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LR-N96044 Description of Proposed Changes PSEEG proposes to exempt the Hope Creek Generating Station (HCGS) from the limitation of 10CFR50, Appendix J, section III.D.3, which requires performance of Type C leak tests during each reactor shutdown for refueling but in no case at intervals greater than 2 years.
The proposed exemption will allow the required periodic tests to be performed during power operation and credit be taken for the surveillance required by Appendix J and Surveillance Requirement 4.6.1.2.
of the Technical Specifications.
Presently, PSE&G can perform Type C tests during power operation for the purpose of post maintenance testing.
Under the existing provisions of 10CFR50, Appendix J, the testing would have to be re-performed at the next shutdown for refueling, regardless of how recently it had been done.
This forces activities which can be safely accomplished with the plant at power into the scope of outages when resources are at a premium.
The proposed exemption wil? allow the option to perform the testing at power as well as during shutdown periods.
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ATTACHMENT 2 IMPACT ON TECHNICAL SPECIFICATIONS
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LR-N96044 Impact on Technical Specifications PSE&G concludes that changes to the HCGS Technical Specifications are not required with this exemption.
The present HCGS Technical Specification 3.6.1.2.
" Containment Leakage" states that Type C tests are included in the combined leakage rate limit of less than or equal to 0.60 La and similarly requires restoration to less than 0.60 La in the specifications' action statement.
Per Type C tests performed during power operation, the as-found values from the most recent test will be applied to the combined leakage (0.60 La) to calculate accurate data to assure compliance with the specification.
The existing HCGS surveillance requirements in specification 4.6.1.2 state that the leakage rates shall be demonstrated at the following test schedule and shall be determined in l
conformance with the criteria specified in Appendix J of 10CFR50 using the provisions of ANSI N45.4-1972.
Neither this specification nor elsewhere within the containment systems Technical Specification is there reference to when (with respect to plant mode) Type C testing should be performed.
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1 ATTACHMENT 3 EVALUATION IN ACCORDANCE WITH 10CFR50.12
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i LR-N96044 l
i Evaluation in Accordance with 10CFR50.12 l
The Nuclear Regulatory Commission allows for exemption from provisions or its regulations if it can'be shown that the i
proposed exemption-meets appropriate criteria established in j
PSE&G has evaluated the proposed exemption against i
the 10CFR50.12 criteria described below:
criterion (a)(1):
"The Commission may, upon application by any l
' interested person or upon its own initiative, grant exemptions from the requirements of the regulations of this part, which are--- Authorized by law, will not.present an undue risk to the public health and safety, and are consistent with the common defense and security."
The exemption is authorized by law upon approval by.the Nuclear
' Regulatory Commission.
This is based on approval for the exemption granted to Houston Lighting and Power Company for its l
South Texas: Project Electric Station dated August 31, 1995.
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addition, the local leak rate testing to be performed either during power operation or during shutdown does not result in an undue risk to the public health and safety because containment integrity.does not depend on the timing of the testing. The probability or consequences of accidents are not increased by changing the testing schedule.
The exemption is consistent with the common defense and security because no changes are proposed that' affect the common defense or security.
i criterion (a) (2) (ii) 3 "The Commission will not consider granting an exemption unless special circumstances are present.
Special circumstances are present whenever---Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule."
PSEEG concludes the proposed exemption meets Criterion (2) (11) because the underlying purpose of the subject portion of 10CFR50,
-Appendix J is to assure that adequate and timely testing of containment integrity is performed.
From the standpoint of J
testing adequacy, when the testing performed is not relevant because the conditions of testing are the same regardless of when it is performed i.e.,
the same test pressure is applied and the same procedure is used.
Taking credit for testing performed during power operation provides the same degree of assurance of containment integrity as taking credit for testing performed during shutdown.
Therefore, requiring the testing to be performed during shutdown is not necessary to achieve the underlying purpose of the rule.
LR-N96044 Criterion (a) (2) (iii) : "The Commission will not consider granting an exemption unless special circumstances are present.
Special circumstances are present whenever---Compliance would result inundue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted, or that are significantly in excess of those incurred by others similarly situated."
This criterion applies because Hope Creek would incur significant and unnecessary costs by continued compliance with the rule as written.
Approval of the exemption will allow significant reduction in refueling outage cost and resource burden by allowing the tests to be credited and/or performed during power operations.
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